HIPAA Interim Final Rule, October 30, 2009
Client Alert | less than 1 min read | 11.06.09
On October 30, 2009, the Department of Health and Human Services (HHS) published an interim final rule conforming HIPAA's enforcement regulations to revisions made under the HITECH Act. The interim final rule strengthens HHS' civil money penalty authority by establishing categories of violations reflecting levels of culpability, increasing the civil penalty amounts, and modifying the affirmative defenses available to covered entities.
Click here to view a presentation on the HIPAA Final Rule [PDF]
Insights
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On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes.
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